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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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DT: Malawi: double taxation agreement, Article 7: Interest and royalties

  1. Any interest or royalty derived from sources within one of the territories by a resident of the other territory who is subject to tax in that other territory in respect thereof and not engaged in trade or business in the first-mentioned territory through a permanent establishment situated therein, shall be exempt from tax in that first-mentioned territory; but no exemption shall be allowed under this Article in respect of any interest or royalty paid by a company to a company which controls, directly or indirectly, more than one-half of the entire voting power in the paying company.
  2. In this Article the term `interest` includes interest on any form of indebtedness, secured or unsecured, and the term `royalty` means any royalty or other amount paid as consideration for the use of, or for the privilege of using, any copyright, patent, design, secret process or formula, trade mark or other like property, but does not include royalties or other amounts paid in respect of the operation of mines or quarries or of other extraction of natural resources or rents or royalties in respect of cinematograph films.